TCH, the ABA, the CBA, and BAFT (collectively, the “Associations”) submitted a comment letter to the CFPB regarding a proposal to revise the Remittance Transfer Rule to establish new exceptions to allow insured depository institutions to disclose estimates of covered third party fees and exchange rates, under certain circumstances. The group expressed appreciation for the Bureau’s proposal, but requested further refinement, including that the Bureau expand the proposed exception for covered third-party fees. The letter explained that there are reasons, beyond the control of even the largest banks, which prevent them from knowing the amount of third-party fees imposed on some remittance transfers; and also requested flexibility in applying the exceptions when an institution crosses certain numerical thresholds that the proposal would establish. Additionally, the group requested a one year transition period before the new rules become effective, so that insured institutions can establish the necessary systems and relationships to comply with the new disclosure regime with minimal disruption to consumers. The letter also recommends that the Bureau encourage broader use of the existing “countries list exception” that allows estimates for remittance transfers to certain countries.
Download the full comment letter here.